1 Supporting Statement for a Request for OMB Review under The Paperwork Reduction Act

1 IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title and Number of the Information Collection

EPA’s Safer Choice Product Recognition Program

ICR Numbers: EPA ICR No. 2302.0 3 OMB Control No. 2070

- 0178

1(b) Short Characterization / Abstract

This renewal information collection request (ICR) addresses the submission of applications to EPA for recognition under the Safer Choice Product Recognition Program ( Safer Choice program )

, formerly known as the Design for the Environment Program

. The Safer Choice program recognizes products where all ingredients meet EPA’s stringent requirements for human health and the

environment as found in the Safer Choice Standard. Under the encouragement of the current p rogram, leading companies have already made grea t progress in developing safer, highly effective chemical products

. Since the program’s inception in 1997, formulators have been using the program as a portal to OPPT’s unique chemical expertise, information resources, and guidance on greener chemistry

. Safer

Choice partners enjoy Agency recognition, including the use of the Safer Choice label on qualifying products

. This ICR would enable Safer Choice to accommodate participation by more than nine formulators each year

, enhance program transparency , and f urther promote chemical safety

.

Safer Choice participates in the development of CleanGredientsTM, a database of safer cleaning product ingredients, which identifies safer formulations and makes forming partnerships easier

. Organized by product functional u se class (e.g., surfactants, solvents, etc.), CleanGredientsTM facilitates a green marketplace where formulators can select functionally appropriate and safer ingredients.

The redesign of chemical products offers opportunities to:

 Remove hazardous chemicals from formulations before they can enter the w orkplace, home, or

environment.

 Advance energy and water efficiency, resource conservation, and innovative technologies.

 Qualify for environmentally preferred product status, increasingly sought by go vernment,

re tailer and consumer purchasers.

Companies formulate products from a broad range of chemicals with a variety of applications

. The Safer Choice p rogram labels cleaning and other chemical

- based products such as dish detergents, laundry deterge nt s , hand soaps, and all

- purpose cleaners for consumer and industrial use

. Cleaning products make up the majority of partnership products, and cleaning product manufacturers have the

greatest demand for program participation by potential partners

. Third

- party profilers review all product applications prior to Safer Choice submission.

The review team carefully reviews each product component

. A literature review, and when appropriate, structural activity relationships, are used to understand each chemical’s hea lth and2

environmental characteristics. The review includes all chemicals, including those in proprietary raw material blends, which ingredient suppliers share with Safer Choice and the third

- party profilers in confidentiality. The review team then compares an ingredient’s characteristics to other chemicals in the same use class, considers possible negative synergies between ingredients, and places the ingredient on a continuum of improvement relative to other similar chemicals

. By means of its review team a nd methodology, Safer Choice provides information to formulators that helps them select from among the safest chemicals in an ingredient class

. Only formulations containing exclusively safer ingredients are recognized by Safer Choice

.

2. NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection

Authority for the Safer Choice p rogram derives from Section 6604(b)(5) of the Pollution Prevention Act (PPA), 42 U.S.C. 13103(b)(5) ( see Attachment A )

, which directs EPA to facilitate the adoption of source

- reduction techniques by businesses, and the Toxic Substances Control Act (15 U.S.C. 2601 et seq.), which encourages safety in technological innovation in chemistry

. In recognition of this statutory dir ective, and through consultation with a broad range of stakeholders, EPA developed

the Safer Choice p rogram.

Safer Choice p rogram information collection activities will assist the Agency in meeting the goals of the PPA by providing resources and recogniti on for businesses committed to promoting and using safer chemical products

. In turn, the Safer Choice p rogram will help businesses meet corporate sustainability goals by providing the means to, and an objective measure of, environmental stewardship. Invest ment analysts and advisers seek these types of measures in evaluating a corporation’s sustainability profile and investment worthiness. 1 It is not surprising then that EPA has heard from many organizations that Safer Choice p rogram partnership is an impor tant impetus for prioritizing and completing the transition to safer chemical products

. The Safer Choice p rogram is also needed to promote greater use of safer chemical products by companies unaware of the benefits of such a change.

Safer Choice has caref

ully tailored its request for information, and especially the Safer Choice

p rogram application forms , to ensure that it only asks for information essential to verifying applicants’ eligibility for recognition.

2(b) Practical Utility/Users of the Data

The information collected by the Safer Choice p rogram is not designed or intended to support regulatory decision

- making by EPA. EPA uses the information collected in the Safer Choice p rogram application to: (1) review products an d their components; (2) complete chemical profiles for each product component to determine its key health and environmental characteristics; and (3) establish a partnership agreement with the company outlining how the company and EPA/ Safer Choice will work together to continually improve the health and environmental profile of the product(s)

.

1 “ Green to Gold: How Smart Companies use environmental strategy to innovate, create value, and build competitive advantage" by Daniel Esty and Andrew Winston, Yale University Press, New Haven, 20063

3. NON

- DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a) Non

- Duplication

Respondents will not be asked to provide informatio n that has been or is currently being collected by EPA, other federal or state agencies, or proprietary sources. The information collected by

the Safer Choice p rogram is unique and is not duplicative of previous information collection requests.

As due dil igence, EPA also checked with trade associations and potential partners to confirm that the information being collected by the Safer Choice p rogram does not exist elsewhere.

3(b) Public Notice Required Prior to ICR Submission to OMB

In proposing to renew this ICR, EPA provided a 60

- day public notice and comment period that ended on May 9, 2016 (81 FR 12097, March 8, 2016). EPA received no comments during the comment period.

3(c) Consultations

Additionally, under 5 CFR 1320.8(d)(1), OMB requires agencies to consult with potential ICR respondents and data users about specific aspects of ICRs before submitting an ICR to OMB for review and approval. In accordance with this regulation, EPA submitted questions to three parties via

e

- mail. The individuals contacted were:

Kathleen Stanton , Director Technical and Regulatory Affairs

American Cleaning Institute KStanton@cleaninginstitute.org

Beth L. Law , Assistant General Counsel

V ice P resident, Stewards hip & Sustainability Consumer Specialty Products Association BLaw@cspa.org

Bill Balek , Director Legislative & Environmental Services

ISSA

- The Worldwide Cleaning Industry Association

bill @issa.com

EPA received no responses to its solicitation for consultations. A copy of EPA’s consultation e

mail to the above potential respondents is included in Attachment E

.

3(d) Effects of Less Frequent Collection

Safer Choice p rogram applications will be received on an ongoing basis over the three years covered by this ICR. The applications are designed to be one

- time information submissions for organizations that wish to participate in the Safer Choice p rogram, with the opportu nity to renew the partnership agreement at the end of the three

- year partnership period

. This means that once every three years, the organization will submit a renewal application to confirm that no changes have been made to ingredients; this step is done in response to correspondence from Safer Choice that reminds4

organizations of the terms of their partnership agreements. Without this information collection mechanism, Safer Choice will not have the ability to assist formulators in developing safer, highly effective chemical products or to formally recognize formulators who have successfully done so.

3(e) General Guidelines

The information collection activities discussed in this renewal ICR comply with all regulatory guidel ines under 5 CFR 1320.5(d)(2).

3(f) Confidentiality

Some information collected by EPA under the Safer Choice p rogram involves confidential

business (CBI) or trade secret information. The Safer Choice p rogram handles all information clai med as confidential business information in accordance with Agency confidentiality procedures (se e 40 CFR part 2, subpart B). The Safer Choice p rogram uses information provided by formulators solely for purposes related to forming the partnership and discl oses the information only to EPA employees and EPA contractors cleared for confidential information with a specific need to know.

3(g) Sensitive Questions

The information collection activities do es not involve any sensitive questio ns.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents and NAICS Codes

The Safer Choice p rogram seeks partners from establishments engaged in the formulation of

end

- us e, for

- sale chemical products.

Below is a list of representative North American Industry Classification System (NAICS) codes and associated industries that may be affected by information collection requirements covered under this ICR. This list is intended to be illustrative; entities f rom other industries may elect to apply for recognition through the Safer Choice p rogram. However, EPA expects that most applications will come from the following industries:

NAICS Code Affected Industry

325510 Paint and Coating Manufacturing

325611 Soap and Other Detergent Manufacturing

325612 Polish and Other Sanitation Good Manufacturing

325910 Printing Ink Manufacturing

325992 Photographic Film, Paper, Plate, and Chemical Manufacturing

325998 All Other Miscellaneous Ch emical Product and Preparation Man ufacturing

4(b) Information Requested

Once a company with an interest in partnership with the Safer Choice p rogram reviews the program materials and decides to apply, the next step for the organization is to submi t the appropriate application.5

(i) Data items :

Applicants for this voluntary program submit information items that vary depend ing upon the class of product. The items include:

Partnership Applications

P roduct manufacturers will submit ingredient information, as described here, through a cloud

based Salesforce system, to a qualified third

- party profiler before submittal to EPA (see Attachment B).

Information submitted to third

- part y profilers :

 Company name and Web site URL;

 Number of employees;

 Company headquarters address and manufacturing address;

 Name, title, phone number, and e

- mail address of the candidate’s signatory contact person (e.g., CEO, or vice president for health and environment) ;

 N ame, title , phone number, and e

- mail address of candidate’s technical contact perso n ;

 Name, title, phone number, and e

- mail address of candidate’s marketing/outreach contact

person;

 Product information (name (s) , UPC, GSA number, sector, production volume, pH, flashpoint, product form , product use );

 Product characteristics on whether or n ot the product is:

o An EPA registered pesticide ;

o A direct release product ;

o A concentrate ;

o Contains enzymes, fragrance, or VOCs ;

o Requires hazard labeling ;

o Ingredient disclosure and performance data submitted ;

 Packaging information :

o Container size and shapes;

o Material;

o Supplier;

 Description of all chemical ingredients , including raw materials and alternative ingredients, in product :

o CAS number;

o Chemical name;

o Trade name ;

o Percent composition;

o Ingredient class;

o Supplier name;

 An SDS for the product and each ingredient;

 Product performance testing (any method of demonstrating product performance is acceptable as long as it is a co mmonly used industry standard);

 Other product information specific to particular product classes, such as flushability / compostabil ity for disposable cleaning wipes;

 If available, any supplemental product or ingredient environmental health and safety information, such as:6 o Biodegradation tests on individual ingredients ;

o Acute aquatic toxicity tests on product as a whole or individual i ngredients ;

o Human health and safety tests ;

 Description of the type of training the company provides to customers on environmental and worker safety matters

.

Information submitted to EPA :

 Summary report, containing same data items as above

.

Adding Third

- Pa rty Partners and Products

Cleaning product manufacturers will submit information about third

- party additions to Safer

Choice through their third

- party profiler

. The three types of third

- party partners and products are private labels, licensees, and toll manufacturers. To be label

- eligible, third

- party product s must contain ingredients identical to those in a Safer Choice

- labeled product.

Information submitted to EPA :

 Safer Choice Form for Adding Third

- Party Partn ers and Products (Private Label Companies , Licensees, or Toll Manufacturers) (EPA Form XXXX

- X) (See Attachment C )

Note that this form will be incorporated into the Salesforce system in the coming months. The fields in the online form in Salesforce will be identical to the PDF form. Until this part of the system is fully incorporated, the Agency will continue to use the PDF application form in

Attachment C.

(ii) Respondent activities :

Applicants for Cleaning and Non

- Cleaning Product Formulation Partnerships

 Review program information, including ins tructions on submitting information to third

party profilers (note: third

- party profilers are separate and distinct from third

- party partners and products; a third

- party profiler is an organization that has partnered with the Safer Choice Program to assist in the evaluation of product formulations against the Safer Choice

Standard. To become a third

- party profiler, the organization must meet stringent requirements as laid out in Section 7 of the Safer Choice Standard .)

 Submit information described in sectio n 4(b)(i) of this supporting statement to third

- party profiler ;

 Establish agreement with third

- party profiler ;

 Submit summary report to Safer Choice ;

 Negotiate / establish Partnership Agreement with Safer Choice ;

 Renew partnership, with no changes needed ;

 Site audit (See Attachment D )

.

Adding Third

- Party Partners and Products

 Review program information ;

 Fill out and submit Safer Choice Program Form for Adding Third

- Party Partners and Products (Private Label Companies, Licensees, or Toll Manufacturers)

.7

5. THE INFORMATION COLLECTED

– AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities

Under the Safer Choice p rogram, EPA engages in the following activities related to the

Formulator application and decision process :

 P rovide applications via Salesforce for potential participants;

 Answer questions posed by potential applicants regarding recognition under the program ;

 Receive the completed applications, review for accuracy, and place any necessary follow

- up calls;

 Apply EPA’s chemical tools and expertise to understand toxicological characteristics of chemical ingredients and to ensure that they are the safest wit hin their functional use class;

 Approve candidates for recognition and not ify both successful and unsuccessful applicants of

the decisions ; and

 Make final decisions about which products may carry the Safer Choice label.

5(b) Collection Methodology and Management

P roduct manufacturers may obtain applicati ons for providing ingredient information by contacting a third

- party profiler. The third

- party profiler will then coordinate with EPA to direct the potential applicant to a link via Salesforce to complete the application online. If a product

manufacturer w ould like to submit information that they believe is Confidential Business Information as defined under the Toxic Substances Control Act, the applica nt should contact EPA by phone.

In collecting and analyzing the information associated with this ICR, EPA will use a telephone system, personal computers, and applicable database software such as Salesforce . EPA will ensure the accuracy and completeness of collected information by reserving the right to request proof of the list of ingredients (e.g., bills of lading, invoices) or other relevant documentation at any time to confirm that candidates have the achieved the criteria for recognition. Th e cloud

- based Salesforce system, which

house s applications and other information related to the Safer Choice program

, is designed to reduce the public and Agency burden related to the application and decision process. However, if a product manufacturer would like to submit information as a hard copy rather than using the Salesforce system, the applicant should contact EP A for the appropriate forms.

5(c) Small Entity Flexibility

EPA expects that some of the participants in the Safer Choice p rogram will be small entities. EPA has designed its application form to minimize respondent burden while obta ining suffic ient and

accurate information. In addition, given the voluntary nature of the collection, EPA expects that respondents will participate only if the benefits of participation outweigh the information collection

burden.

5(d) Collection Schedule

Organizations may submit an application for recognition at any time.8

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a) Estimating Respondent Burden

The average respondent burden is estimated to be 16 hours for new product formulators and 8 hours for product formulators wishing to add third

- party partners and products (see Exhibit 6.2). EPA used professional judgment to arrive at a burden estimate and then consulted representatives from the participant categories to make sure the burden estimates were reasonable (see section 3(c)).

EPA expects that for a typical product formulator, program and application review will take

about 2 hours (1 managerial, 1 technical)

. Filling out and submitting third

- party profiler information request forms will take about 6 hours ( 5 technical, 1 clerical), and then establishing an agreement with

the third

- party profiler will take about 3 hours (1 managerial, 1 technical, 1 clerical)

. Submitting a

summary report to Safer Choice will take about 2 hours (1 managerial, 1 technical)

. Finally, establishing a Partnership Agreement with Safer Choice will take 3 hou rs (1 managerial, 2 technical).

For a typical addition of a third

- p arty partner and products, program and application review

will take about 2 hours (1 managerial, 1 technical). Filling out and submitting one Safer Choice Program Form for Adding Third

- Party Partners and Products (Private Label Companies, Licensees, or

Tol l Manufacturers) is estimated to take about 2 hours ( 1.5 technical

, 0.5 clerical ). On average, a partner will fill out 3 third

- party partners and products forms annually. Therefore, it is estimated that it will take one respondent 6 hours ( 4.5 technical

, 1.5 clerical) to add third

- party partners and products.

In addition to the burden associated with first

- time submission of applications, each formulator has the opportunity to renew its Partnership Agreement at the end of the three

- year partnership period

. This means that once every three years, the formulator re

- submits its application for each partnership product to confirm that no changes have been made to ingredients

. EPA then evaluates the application

. EPA estimates that the partnership renewal proces s will take 4 hours ( 3 technical, 1 clerical) for cleaning and non

- cleaning product formulators.

For purposes of this ICR, EPA expects that 108 (see Section 6 (e) on estimating the respondent universe) product formulators will choose to renew their partner ships

. Furthermore, EPA anticipates that one in ten product formulators (i.e., 12) over the three

- year period of this ICR will need to make improvements to their formulations so that they contain the safest ingredients within each functional use class; in these cases, a new partnership approval process, as described above, will be triggered

. The associated burden for completing the new partnership approval process is assumed to be the same as

first

- time submission.

As part of the application process, the t hird

- party profiler will also reserve the right to conduct

site audits and desk audits

. The purpose of site visit s to facilities is to verify that each partnership product contains the same ingredients, in the same volumes, that are reported by the company as part
of the Safer Choice recognition process

. The site auditor will review batch tickets associated with each recognized product to ensure that ingredient claims are accurate

. Additional audit procedures are listed

in Attachment D of this document. For purposes of estimating annual cost and burden in Exhibit 6.2, it is assumed that about 33% of formulators will get audited on

- site each year over the three

- year period

of this ICR

. Each site audit is estimated to require two hours of a technical person’s time and one hour of a clerical person’s time. Desk audits will also be conducted by third

- party profilers. Prior to the desk audit, formulators will be responsible for providing a list of all ingredients for each recognized product, product labels display ing the Safer Choice logo, private label information (where applicable),9

and various other materials. For the purposes of estimating annual cost and burden in Exhibit 6.2, it is

assumed that 66% of formulators will be subject to a desk audit each year over the three

- year period of this ICR. Each desk audit is estimated to require two hours of a technical person’s time and two hours of a clerical person’s time. As with the site audits, additional information on desk audits can be found

in Attachment D of thi s document.

6(b) Estimating Respondent Costs

EPA estimates an average loaded hourly labor rate (base hourly rate plus fringe and overhead) of $ 8 3 for managerial staff, $ 73 for technical staff, and $ 32 for clerical staff. These three labor rate estimates are based upon manufacturing industry wage data from the Bureau of Labor Statistics (BLS) Employer Costs for Employee Compensation, Supplementary Tables from September 2015 . The hourly labor rates include a 17% overhead; t his overhead rate is used for consistency with OPPT economic analyses for two major rulemakings: Wage Rates for Economic Analyses of the Toxics Release Inventory Program 2 and the Revised Economic Analysis for the Amended Inventory Update Rule: Final Report

. 3 In addition, the hourly labor rates have been rounded for the purposes of this ICR. The type of staff needed to complete the Formulator’s applications and their associated hourly labor rates were verified by contacting representatives from the particip ant categories.

The derivation of labor rates for managerial, technical, and clerical staff appears in Exhibit 6.1.

Exhibit 6.1. Derivation of Loaded Wage Rates in 2015 $

Labor
category Wage Fringe

Benefit Fringes as

% wage Overhead

% wage Fringe +

overhead

factor Loaded

Wages Loaded

Wages (rounded) (a) (b) (c)=(b)/(a) (d) (e)=(c)+(d)+1 (f)=(a)  (e)

Managerial 4 $ 49.78 $ 24.70 49.62 % 17% 1. 67 $ 82.94 $ 83 .00

Professional/

Technical 2 $ 42.76 $ 23.07 53.95 % 17% 1. 71 $ 73.10 $ 73 .00

Clerical 2 $ 19.04 $ 9. 61 50. 47 % 17% 1.6 7 $ 31.89 $ 3 2 .00

In exhibit 6.2 is the breakdown of burden costs, assuming 16 hours for completing the partnership agreement , 11 hours for renewals and associated audits, and 8 hours for cleaning product formulators wishing to add third

- party partners and products

. The third

- party profiler verification process for cleaning products also adds a n operating and management (O&M) cost of about $ 12,400 per company per application. Thi s cost estimate is from NSF International, which has experience as a third

- party profiler of ingredient characteristics. For this ICR, it is assumed that typical product

manufacturer s will submit four prod ucts in an application. Each product is assumed to contain 2 ingredients at $ 650 each, 1 proprietary ingredient at $ 1,300 each, and 3 CleanGredients TM ingredient at no charge, for a total of $ 2

, 6 00 per product. In addition, a $ 500 administrative fee per product is

2 EPA, 2002b. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch, Wage Rates for Economic Analysis of the Toxics Release Inventory Program. Washington, DC: June 10, 2002.

3 EPA, 2002 . U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch. Revised Economic Analysis for the Amended Inventory Update Rule: Final Report. Washington, DC. August 2002.

4 Bureau of Labor Statistics (BLS) Employer Costs for Employee Compensation, Supplementary Tables. From Supplementary Table 2, Employer costs per hour worked for employee compensation and costs as a percent of total compensation: Private industry workers in manufacturing industries, by occupational group, establishment size and bargaining status, September 2015

. A vailable at: htt p://www.bls.gov/ncs/ect/sp/ecsuptc 36 .pdf10

assumed. The total will be $ 12,400 per comp any per application. No additional capital or O&M costs are incurred by respondents under this ICR.11

Exhibit 6.2. Estimated Annual Burden and Costs to Respondents

Collection activity Hours and Costs Per Respondent Total Hours and Costs

Managerial Tech nical Cler ical Response

Hours/Y ea r Labor

Cost/Y ea r Capital O & M

Cost* Number of

Respon.** Total

Hours/Y ea r Total

Cost/Y ea r $ 83 /H ou r $ 73 /H ou r $ 32 /H ou r Cost

Partnership Agreements

Review program inf

ormation 1.0 1.0

- 2.0 $ 156 $0 $0 4 4 8 8 $ 6, 864

Fill out and submit third

- party information request form

- 5 .0 1. 0 6.0 $ 397 $0 $0 44 2 64 $ 17,468
Establish agreement w ith third

party profiler 1.0 1.0 1.0 3.0 $ 18 8 $0 $12,400 44 1 32 $ 553,872

Submit summary report to Safer

Choice 1.0 1.0

- 2.0 $ 156 $0 $0 44 88 $ 6,684
Negotiate / establish Partnership Agreement w ith Safer Choice 1.0 2.0

- 3.0 $ 229 $0 $0 44 1 32 $ 10,076

Subtotal 4.0 10.0 2.0 16.0 $ 1,126 $0 $12,400 44 704 $ 595,144

Renewals and Audits

Renew partnership, w ith no changes needed

- 3 .0 1.0 4 .0 $ 251 $0 $0 36 144 $ 9,036

Desk audit

- 2.0 2.0 4.0 $ 210 $0 $0 2 4 96 $ 5,040

Site audit

- 2.0 1.0 3.0 $ 178 $0 $0 1 2 36 $ 2,136

Subtotal

- 7 .0 4

. 0 11 .0 $ 639 $0 $ 0 36 276 $ 16,212

Adding Third

- Party Partners and Products

Review program information 1.0 1.0

- 2.0 $ 156 $0 $0 77 154 $ 12,012

Fill out and submit form for adding third

- party partners and products

- 4.5 1.5 6.0 $ 377 $0 $0 77 462 $ 28,991

Subtotal 1.0 5.5 1.5 8.0 $ 533 $0 $0 77 6 16 $ 41,003

TOTAL 1 5 7 1,5 96 $ 652,359

* The cost for third

- party profiler review and verification assumes that the typical application submitted by a cleaning product manufacturer will contain four products , each with 2 ingredients ( $ 650 each ), 1 proprietary ingredient ( $ 1,300 )

, and a $ 500 administrative fee. The total cost per product is $3,100. The total will be $ 12,400 per company per application. **This column reports the number of annual respondents after accounting for the partnership renewal process. Assumes that on e in ten formulators over the three

- year period will need to make changes to their formulations and go through a new partnership pr ocess which includes same collection steps. On an annual basis, this translates to 4 product formulators (for a total of 44 partnership agreements ). Also assumes that about 33% of the remaining product formulators will be subject to site audits each year (i.e., 12) and that

about 66% (i.e., 24) will be subject to desk audits each year

. See Section 6(a) for additional explanation. Assumes that 77 partners will fill out third

- party partners and products forms

based on historical data

. See Section 6(e) for additional explanation.12

6(c) Estimating Agency Burden

Exhibit 6.3 presents the estimated Agency burden hours and costs associated with the

information collection activities under this ICR

. EPA based its burden estimates on its experience managing other voluntary programs.

EPA expects that review of the program application forms for a typical product

formulator will take about 1 hour (1 technical)

. Reviewing the third

- party profiler information

summary report will take abo ut 5 hours (5 technical). Establishing a Partnership Agreement

with the formulator will take about 3 hour s ( 1 managerial, 2 technical). Reviewing the partnership renewal and assuming that no changes are needed is estimated at 2 hours (1 managerial, 1 technical) , and reviewing audit summaries is estimated at 1 hour (1 technical).

The burden f

or r eviewing the Safer Choice Form for a dding third

- party partners and

p roducts is estimated to take about 2 hours ( 2 technical).

6(d) Esti mating Agency Costs

Agency labor costs are calculated based on hourly basic rates for federal employees in the Washington

- Baltimore area published by the Office of Personnel Management effective January 2016 5

. The average hourly labor rate for managerial staff is estimated as the rate for a

GS

- 13 Step 5 employee, for technical staff as a GS

- 10 Step 10 employee, and for clerical staff

as GS

- 5 Step 1

. These GS

- level assumptions are consistent with those used in past EPA OPPT

ICRs

. The hourly rates were multi plied by an assumed loading factor of 1.6 to reflect Federal fringe benefits and overhead

. This loading factor is from an EPA guide, Instructions for Preparing Information Collection Requests (ICRs) (OPPE, 1992, page 30, footnote 9)

.

The resulting average hourly labor rates, rounded to the nearest dollar amount, are $ 80 for managerial staff, $ 59 for technical staff, and $ 27 for clerical staff

. The Agency expects most activities related to this ICR to be performed by managerial staff ( 14 percent) and

techni cal staff ( 86 percent).

5 OPM, 2016. Salary Table 2016

- DCB , Washington Baltimore Northern Virginia, DC

- MD

- PA

- VA

- WV

. Available at http://www.opm.gov/oca/1 6 tables/pdf/dcb_h.pdf13

Exhibit 6.3. Annual Agency Burden/Cost

Collection activity Hours and Costs Per Respondent Total Hours and Costs

Managerial $ 80 /H our Technical

$5 9 /H ou r Agency

Hours/Y ea r Labor

Cost/Y ea r Capital/

Startup Cost O & M

Cost Number of

Respon.* Total

Hours/Y ea r Total

Cost/Y ea r

Cleaning and Non

- Cleaning Products

Review program application

forms

- 1.0 1.0 $ 59 $0 $0 4 4 4 4 $ 2, 596

Review third

- party profiler

summary

- 5 .0 5 .0 $ 295 $0 $0 44 22 0 $ 1 2,980

Negotiate / establish Partnership Agreement w ith formulator 1 .0 2 .0 3 .0 $ 198 $0 $0 44 1 32 $ 8,712

Review partnership renewal,

with no changes needed 1.0 1.0 2.0 $ 139 $0 $0 36 72 $ 5,004

Review audit summaries

- 1.0 1.0 $ 59 $0 $0 36 36 $ 2,124

Subtotal 2 .0 10.0 12.0 $ 750 $0 $0 8 0 504 $ 31,416

Adding Third

- Party Partners and Products

Review Safer Choice form for adding third

- party partners and products

- 2 .0 2.0 $ 118 $0 $0 77 1 54 $ 9,086

Subtotal

- 2.0 2.0 $ 118 $0 $0 77 1 54 $ 9,086

TOTAL 157 6 58 $

40,502

* This column reports the number of respondents after accounting for the partnership renewal process. Assumes that one in ten formulators will need to make changes to their formulations and go through a new partnership process which includes same collection steps , i.e . 4, for a total of 44 annually. Assumes that 77 partners will fill out third

- party partners and products forms based on historical data

.14

6( e ) Estimating the Respondent Universe and Total Burden and Costs

EPA estimates that 120 formulators will submit applications over the thr ee

- year life of

the clearance. EPA expects the participation will ramp up over the three year period but

, for the purposes of estimating annual cost and burden in Exhibit 6.2, i t is assumed that 40 product formulator application s will be submitted each year. This estimate is based on historical data and the assumption that participation will increase over the next three years in response to greater consumer demand for safer produ cts and increased awareness of the Safer Choice label. EPA also expects 40 renewals per year, 10% of which will need to make changes to formulations and go through a new partnership process. Additionally, EPA estimates that 77 applications will be

received annually to add third

- party partners and products. This estimate is based on the average number of partners that submitted third

- party partners and products applications over the past five years (62) and is expected to increase over the course of this ICR period due to the new label (25%). Therefore, it is estimated that a total of 157 respondents will submit applications under the Formulator program each year. The annual burden hours and cost associated with this information collection are 1,596 hours and $652,359 respectively.

6( f ) Bottom Line Burden Hours and Cost Tables

a. Respondent Tally

Exhibit 6.4 below summarizes the total annual estimat ed respondent burden and cost. These estimates represent the average burden in any give n year over the three years covered by

this ICR.

Exhibit 6.4. Total Annual Estimated Respondent Burden and Cost Summary

Total # of Respondents Total Burden Hours Annual Cost

157 1, 596 $ 652,359

b. Agency Tally

Exhibit 6.5 below summarizes the total annual est imated agency burden and cost. These estimates represent the average burden in any given year over the three years covered by this

ICR.

Exhibit 6.5. Total Annual Estimated Agency Burden and Cost Summary

Burden Hours Annual Cost

6 58 $ 40,50 2

6( g ) Reasons for Change in Burden

This request reflects a n in crease in the estimated annual burden of 362 hours (from 1,234

hours to 1,596 hours) from that currently in the OMB inventory

. EPA reduced p er

- response b urden estimates compared to those in the previous ICR based on expected efficiencies created by using the Salesforce

- based Safer Choice Community on the part of respondents. However, the15

number of respondents increased

, compared to the prior ICR

, due to hi storical experience and

increases in the expected future number of responses due to greater consumer awareness and demand for products with the Safer Choice label

. Th i s change i s an adjustment

.

6( h ) Burden Statement

The annual public burden for this col lection of information is estimated at 16 hours per response for formulators , 11 hours for formulators renewing a partnership that requires changes,

and 8 hours for cleaning product formulators wishing to add third

- party partners and products

, including ti me for reviewing instructions, gathering information, and completing and reviewing the application

. Burden is defined in 5 CFR 1320.3(b). An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The OMB control numbers for EPA’s regulations in title 40 of the CFR, after appearing in the Federal Register, are listed in 40 CFR part 9 and included on the related collection instrument or form, if appli cable.

The Agency has established a public docket for this ICR under Docket ID No. EPA

- HQ

OPPT

- 20 15

- 0437 , which is available for online viewing at www.regulations.gov, or in person viewing at the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Const itu tion Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Fri day, excluding legal holidays. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the Pollution Prevention and Toxics Docket is (202) 566

- 0280. You may submit comments regarding the Agency's need for this information, the accuracy of the provided burden estimates and any suggested methods for minimizing respondent burden, including the use of automated collection techniques.

Submit your comments, referencing Docket ID No. EPA

- HQ

- OPPT

- 2015

- 0437 and

OMB Control No. 2070

- 0178 , to (1) EPA online using www.regulations.gov (our preferred method), or by mail to: Document Control Office (DCO), Offi ce of Pollution Prevention and Toxics (OPPT), Environmental Protection Agency, Mail Code: 7407T, 1200 Pennsylvania Ave., NW, Washington, D.C. 20460, and (2) OMB by mail to: Office of Information and Regulatory Affairs, Office of Management and Budget (OMB) , Attention: Desk Officer for EPA, 725 17th Street, NW, Washington, DC 20503.16 ATTACHMENTS TO THE SUPPORTING STATEMENT

Attachments to the Supporting Statement are available in the public docket established

for this ICR renewal under docket id entification number EPA

- HQ

- OPPT

- 20 15

- 0 437 . These attachments are available for online viewing at www.regulations.gov or otherwise accessed as

described above in Section 6(h ) of the Supporting Statement

.

Attachment A: 42 USC 13103

- Pollution Prevention Act Section 6604

Attachment B: Safer Choice Program: Product and Ingredient Submissions in

Salesforce

Attachment C : Safer Choice Program: Form for Adding Third

- Party Partners and

Products (Private Label Companies, Licensees, or Toll

M anufacturers)

Attachment D : Safer Choice Program: Audit Process Guidance

Attachment E: Copy of Consultations Message Sent by EPA to Potential Respondents